The Renewable Fuels of Non-Biological Origin (RFNBO) framework, established under the Renewable Energy Directive (RED II and RED III), provides the regulatory foundation for renewable hydrogen and hydrogen-derived fuels in the European Union. Its primary objective is to ensure that these fuels deliver genuine greenhouse gas emissions reductions while supporting the EU’s climate neutrality and energy transition goals.
This framework applies to producers, suppliers, and users of renewable hydrogen and e-fuels across the European market. It is particularly relevant for sectors where direct electrification remains challenging, including heavy industry, aviation, maritime transport, and chemical production. Compliance with RFNBO requirements is increasingly becoming a prerequisite for market access, regulatory recognition, and participation in renewable energy targets.
Key focus areas of the RFNBO framework
- Renewable electricity sourcing: RFNBOs must be produced using electricity generated from renewable energy sources, supported through direct connections or renewable power purchase agreements.
- Additionality requirements: Renewable electricity used for RFNBO production must contribute to the deployment of new renewable energy capacity, ensuring that hydrogen production drives additional decarbonization.
- Temporal and geographic correlation: Hydrogen production must be linked to renewable electricity generation within defined time periods and geographic regions, providing assurance that renewable electricity is genuinely available when fuel production occurs.
- Greenhouse gas emissions performance: RFNBOs must achieve significant life cycle greenhouse gas emission reductions compared to fossil fuel alternatives based on harmonized EU accounting methodologies.
Greenhouse gas accounting requirements for RFNBOs
A central element of RFNBO compliance is the calculation and verification of life cycle greenhouse gas emissions. Key principles include:
- Comprehensive life cycle assessment covering electricity generation, hydrogen production, fuel conversion, transport, and distribution
- Use of transparent and traceable activity data across the value chain
- Application of the methodology defined in Delegated Regulation (EU) 2023/1185
- Demonstration of at least 70% greenhouse gas emission savings compared to the fossil fuel comparator
- Documentation of electricity sourcing, temporal matching, and geographic correlation requirements
- Preparation of audit-ready evidence to support certification and regulatory reporting
Delegated Regulations supporting RFNBO compliance
The RFNBO framework is supported by two key Delegated Regulations adopted by the European Commission:
- Delegated Regulation (EU) 2023/1184: Establishes rules for renewable electricity sourcing, additionality, temporal correlation, and geographic correlation.
- Delegated Regulation (EU) 2023/1185: Defines the methodology for calculating life cycle greenhouse gas emissions and demonstrating compliance with emission reduction requirements.
Together, these regulations provide the technical and methodological basis for RFNBO certification and verification throughout the European market.
Why accurate LCA and GHG accounting matter
RFNBO certification depends on robust, transparent, and scientifically credible greenhouse gas calculations. Accurate life cycle assessment and emissions accounting enable companies to:
- Meet RED II and RED III compliance requirements
- Support RFNBO certification and third-party verification processes
- Identify opportunities to reduce emissions and improve project performance
How Prelude Analytics can support your RFNBO compliance
At Prelude Analytics, we help hydrogen producers, e-fuel developers, technology providers, and industrial companies develop regulation-ready LCA and GHG models that support RFNBO compliance and certification.
As RFNBO requirements continue to evolve, proactive preparation is essential. Our team can help ensure that your project data, emissions calculations, and compliance documentation are accurate and compliant.
Contact Prelude Analytics
Book a free introductory consultation with our team to understand your compliance pathway and identify the most effective approach for your project.